Heald,
J.:—We
are
in
full
agreement
with
the
reasons
given
by
the
learned
Tax
Court
judge
for
dismissing
the
taxpayer’s
appeal.
We
think
that
he
correctly
applied
the
provisions
of
paragraph
227.1(2)(b)
of
the
Income
Tax
Act,
R.S.C.
1952,
c.
148—as
amended
by
S.C.
1979-71-72,
c.
63,
to
the
facts
of
this
case.
Accordingly
the
section
28
application
is
dismissed.
Appeal
dismissed.
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